It was a simple two line call-out on the LinkedIn site of global New Zealand networking group Kea that caught Adam Greenwell’s attention on January 13, 2013.
The Californian-based president of Worldwide Investment Consultants, Julie Roberts, had written on Kea’s online noticeboard; “I have a business associate who wants to invest in New Zealand businesses. If you are looking for an investor or know of someone who is, contact me and I will make an introduction.”
Greenwell assumed Roberts was an ex-pat New Zealander, because she was writing on Kea. Kea has the support of New Zealand Trade and Enterprise (NZTE), which lent an air of legitimacy to the call-out. He admits now though that he did not discuss with Roberts what her nationality was. Her LinkedIn profile details jobs and education centred in California.
The initial response Greenwell got from Roberts was from “Julie’s associate” and simply signed “S”.
In any event the correspondence suggested good prospects of sourcing large amounts of international funding for sustainable New Zealand projects, a cause espoused by his mother, Liz Greenwell, who is a New Zealand-based professor at New York-based Energime University. Energime is described on the internet as being aimed at re-establishing a sustainable planet.
Within 10 days of that message Roberts’ “business associate” Steven Medley, who Greenwell describes as an American investment banker, was delivering contracts by email that would make Greenwell the NZ representative for two financial service providers Medley had set up in New Zealand – Oppco Savings & Loans Ltd (now NZ OSL Services Ltd), and Ruznakk Savings LP. Both featured in the first story in this series here, with a connection to the profoundly dubious Filipino stock promoter Pearlasia Gamboa, whose latest venture is a gold mining operation based in South Africa.
Greenwell’s mother’s house at 44 Carter Crescent, Awapuni, Palmerston North would be the physical office for the businesses, satisfying the requirements for NZ registered financial service providers to have a physical NZ presence and representative. Below is 44 Carter Crescent, with the picture sourced from QV. This is now the business address of the NZ registered financial service providers NZ OSL Services Ltd, and Ruznakk Savings LP.
Greenwell, by his own admission, is not a financier, nor has he ever been an investment banker. He owns a company, Town Green Music Ltd and writes his own music. One of his performances, about the Wellington suburb of Oriental Bay, is on YouTube.
His musical ambitions and lack of financial services expertise have not stopped him taking on a role with these financial service providers, with relish, as shown by a trail of correspondence provided to interest.co.nz. He appears close to his mother and is eager to further her lifelong work and goals for a more sustainable world. One website shows his mother included in a “hall of heroines” of “empowered women” alongside Mother Teresa, Oprah Winfrey, Rosa Parks and Princess Diana. It also shows on the same page her certificate for her role as a global ambassador “for peace and human rights” in NZ on behalf the “Multipurpose Inter Parliamentary Union” and her work for Global Cooperation Day.
$US1 billion promise
Greenwell says that not long after he became involved with the financial service providers, Medley promised him funding via US$1 billion worth of sukuk bonds, sourced from Dubai to invest in NZ in some sort of sustainable infrastructure project. Sukuk bonds are structured in a way that provides returns to investors without infringing Islamic law. Greenwell thought the Christchurch rebuild after the big 2011 earthquake was the ideal place to start.
In 2014 he wrote to the Minister for Canterbury Earthquake Recovery, Gerry Brownlee, and to Minister for Economic Development, Steven Joyce, outlining investment ideas. He then flew to Christchurch and met with a member of the Canterbury Earthquake Recovery Authority (CERA) and the Canterbury Business Association in July of that year. In his detailed review of that meeting (also provided to interest.co.nz) he outlines Energime Group’s interest in making a large-scale multi-use investment in New Zealand involving sustainable power-purchase agreements, waste management, water enhancement, the clean-up of rivers, food production, sustainable housing, rail service re-fits for transportation of patented-energy supply product, social housing and education.
It would be modelled, he said on a “public-private partnership paradigm”. He added that Energime’s patented products had been rated by NASA and technology-tested and output-certified by Rolls Royce and the British Atmospheric Data Centre.
“Both the Energime and sukuk investment interest arose out of international support for new methods of social, ethical and responsible investment devised by my mother, Liz Greenwell,” he wrote to the CERA and business association people he had met with. “Can we, all of us together, water the fields of humanity, and bring about a harvest so great, that it will take the world to pick the fruit, a harvest that is civil society? I think we can,” he quoted from one of his mother’s writings.
“I was advised to ultimately take up my investment proposal – including the offer of a minimum US$1 billion bond for investment in the New Zealand economy – with the National Infrastructure Unit in the New Zealand Treasury,” Greenwell’s detailed review finishes.
So far neither the bonds nor any project has materialised. Greenwell is still certain it will happen, but after three years of effort – he even offered to waive fees – he expressed his frustration about how long things seem to be taking.
Government guarantee sought
In a letter from Steve Medley to Liz Greenwell dated March 29 this year, provided to interest.co.nz by Adam Greenwell, Medley says “our company” NZ OSL Services, “kindly requests that your home at 44 Carter Crescent, Palmerston North, act as our registered New Zealand office.” Companies Office records show Medley as NZ OSL Services’ sole shareholder.
Medley goes on to say; “Based on our review of your proposals, we believe our sukuk sources should be interested in funding the projects provided there is a government guarantee and/or an income generating government/large company project.”
“We welcome you into our business operation. We look forward to working with you through our appointment of Adam as a director, and to meeting you in person very soon,” Medley writes.
Directorship in progress or confirmed?
Fast forward to June 2016 and Greenwell has moved up a notch from representative to director of NZ OSL Services Ltd, according to the Companies Office register. Curiously, Greenwell contradicts the official public record: he says his directorship has not yet been confirmed as it is “awaiting approval”, and provides a screenshot in support (below), along with other supporting paperwork.
Yet the official record, which is not in agreement with this screenshot, is unambiguous. Greenwell has been a director of NZ OSL Services since April 26, 2016, and appears not to understand this.
Anti-money laundering compliance
Greenwell has also provided to interest.co.nz extensive correspondence between himself and the Ministry of Business, Innovation and Employment’s registries integrity and enforcement team regarding his lapsed directorship application along with other issues dealt with by Rob Milnes, compliance officer for the financial integrity unit at the Department of Internal Affairs.
Milnes monitors some NZ companies to ensure compliance with the Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act). Milnes said he could not comment about Greenwell, but Greenwell has put him in a loop of correspondence that he has been dispatching since initial queries from interest.co.nz. Included in that loop is the Prime Minister, John Key and his deputy, Bill English.
In one of Greenwell’s responses to Milnes he expresses frustration about the lack of take-up on his investment proposal, his mother expresses her distaste at her address being linked to anything to do with the AML/CFT Act, and Greenwell, as he does often, uses the Kea link, seemingly to vindicate the legitimacy of his involvement with the financial service providers.
In one of the pieces of correspondence (following) Greenwell leaves out the names of Steven Medley who he did the original contract with and Medley’s father, Stan Medley, who he said he had most dealings with.
So here is some of that correspondence:
Mr Rob Milnes
Financial Integrity Unit
Department of Internal Affairs
Auckland, NEW ZEALAND.
Dear Mr. Milnes,
Introduction: From Adam Greenwell
I refer to your letter addressed to The Compliance Officer; Oppco Savings & Loans Limited, 44 Carter Crescent, Palmerston North 4412, dated 13 May 2015; as well as a separate letter addressed to The Compliance Officer; Ruznakk Savings LP, 44 Carter Crescent, Palmerston North 4412 dated 13 May 2015.
Both letters, sent by post, were received today, 18 May 2015, at the above address.
Both letters were identical in content, with the only exceptions being that Ruznakk Savings LP (FSP67903) was cited as having been registered as a Financial Services Provider (FSP) since 24 March 2011; and Oppco Savings & Loans Limited (FSP61601), was cited as having been registered as an FSP since 4 February 2011.
The thrust of your letter centered around the obligations of reporting entities under the Anti-Money Laundering and Countering Financing of Terrorism (“AML/CFT”) Act 2009. In reply, please find two letters; one from Professor Liz Greenwell; and the second one from myself, Adam Greenwell.
Letter one, from Liz Greenwell
Liz Greenwell, apparently utterly oblivious to the obligations of reporting entities under the AML/CFT Act act, such as the financial service providers registered at her address, indignantly expresses her distaste at her address being linked to anything to do with this law.
Dear Mr Milnes,
Please amend your records.
1) I am the owner of 44 Carter Crescent, Palmerston North 4412, New Zealand.
2) I do not own Oppco Savings & Loans Limited.
3) I do not own Ruznakk Savings LP.
4) Please direct your correspondence to the owner of each of these companies.
5) Please ensure that no further letters of this nature are sent to my address, without a name, because it implies that the owner of the home is the person you are writing to.
6) I am deeply offended by your linking of my address, and subsequently, my name, as the owner of the home, to the Act of Parliament you have referred to in most heavily bold print; in your letter of 13 May 2015, received today, 18 May 2015. This Act has absolutely nothing whatsoever to do with me.
7) Perhaps my enclosed statement will enlighten you as to why such a letter from you, quoting such an Act, would be seen by me as highly offensive, and most inappropriate.
Having pioneered the initiative Social, Ethical and Responsible Investment, I am, along with my son and production assistant, Adam Greenwell, working to reach; and working along with, some of the world’s top financiers, in the implementation and extension of my lifelong works of global social merit; and my overall global vision of Watering the Fields of Humanity, worldwide.
Prof. Liz Greenwell
Letter two, from Adam Greenwell
In the second piece of enclosed correspondence (following), it is painfully clear that Adam Greenwell understands no better than his mother what connection there might be between the financial services providers registered at her address and anti-money laundering requirements:
Dear Mr Milnes,
I write in my capacity as production assistant to Prof. Liz Greenwell. Out of a wide- ranging plethora of international support for Prof. Greenwell, and her work of proven global merit; came the American parties who appointed me as New Zealand representative for Oppco Savings & Loans Limited, and Ruznakk Savings LP.
The following is a passage from your Department of Internal Affairs website: “The Anti- Money Laundering and Countering Financing of Terrorism Act 2009 came into full force on 30 June 2013.
The Department of Internal Affairs will be supervising casinos, non-deposit taking lenders, money changers, money remitters, payroll remitters, debt collectors, factors, financial leasors, safe deposit box vaults, non-bank credit card providers, stored value card providers and cash transporters.”
This being the case, I am unsure as to where Ruznakk Savings LP, and Oppco Savings & Loans Limited, fit within that criteria. In any case, please note that I am not the Compliance Officer for either company. Your letter of 13 May 2015 states “Reporting entities have a number of obligations under the AML/CFT Act, which include appointing a Compliance Officer, maintaining a risk assessment and AML/CFT compliance programme, submitting an annual report and a biennial audit.”
Next, Greenwell introduces “Mr “ and “his son, S”. We will get to who these two are, in a moment.
I have therefore set up this particular distribution of emails between yourself; Mr , who facilitated my selection and agreements which I am about to send in a separate email; his son, S, with whom I signed those agreements, and myself. Please sign, scan and send your letter of 13 May 2015 and questions, to this email distribution, to assist the (owners) in making their assessments, then advising accordingly.
Mr … was introduced to me by an expatriate New Zealander, connected to a group affiliated to New Zealand Trade and Enterprise. Mr Medley was consulted by Stan Lee, Hollywood’s highest-grossing film producer of all time, to take Mr Lee’s companies public on more than one occasion and to put right a deal that went awry between Mr Lee and his former friend.
Mr …. also continues to be linked to – and consulted as an expert witness, and specialist on taking companies public by – the US Department of Justice, the SEC, and various governments.
He is connected to wealthy UAE financiers willing to invest a minimum 1 billion USD on projects and programs around the world, as related in Prof. Greenwell’s attached statement.
Greenwell expresses frustration about the lack of take-up of his investment proposal.
On December 17 2013, the Minister of Economic Development was advised by Mr …., through me, of such a high level of investment interest – USD 1 Billion+ – in the New Zealand economy.
That large-scale interest came about through the pioneering initiatives of Social, Ethical and Responsible Investment that Prof. Liz Greenwell has referred to in her first letter, in this communication.
In keeping with Prof. Liz Greenwell’s overall global vision of Watering the Fields of Humanity worldwide, Mr … and I then focused on large company and government funding for purposes as related in Prof. Greenwell’s attached statement. From that, having developed a track record in helping procure large-scale government funding and investment, I would be in a better position to revisit the domain of taking companies public, as a private occupation. I was already receiving some of the world’s best advice to do that.
Despite diligent and painstaking efforts on my part, in approaching companies and CEOs about going public and/or listing on foreign stock exchanges, there was very little traction, if any.
As mentioned, my work for Oppco Savings & Loans Limited, with regard to taking companies public, was frustratingly difficult. I would sometimes meet and/or talk to senior government officials and captains of industry whom I would not hear from again. Attempts to set up paper trails and “Records of Discussion” were unsuccessful. Even high-level government officials insisted on phone calls with no follow-through in writing.
I can say that Ruznakk Savings LP is inactive, at this juncture, because company procedure involves the appointment of other representatives, further specialised training in financial services and further training in the matching of investors with prospective companies. I could only grow this enterprise were my efforts with Oppco Savings & Loans Limited duly credited, and payment duly awarded.
Please stand by for further emails and information regarding company procedures as delineated by the companies concerned; correspondence with the New Zealand Government and government officials, which will immediately follow this communication.
Now for “Mr “ and “his son, S”: Greenwell means Steven Medley, with whom he made the original contract, and Medley’s father, Stan Medley, with whom, he said to interest.co.nz, he had most dealings.
When asked whether he was aware that, in September 2001, Stan Medley was part of a group charged with fraud and violating broker registration requirements that resulted in US$20 million in illegal profit through the selling of unregistered securities to investors, Greenwell maintains this “issue” was “corrected” in an “article”, last year. Be that as it may, in 2005, the District Court found that Stan Medley violated Sections 5(a) and 5(c) of the Securities Act, and imposed an order that Medley disgorge $2,647,964.29 in “ill-gotten gains”, along with second-tier civil penalties totalling US$165,000. In 2008, agreeing with the District Court’s description of Medley’s firm as a “sham incubator”, the US Appeal Court jibbed at imposing the second-tier civil penalties on Medley without a further evidentiary hearing, but affirmed the disgorgement of ill-gotten gains. In 2010, the SEC abandoned its attempt to secure second-tier civil penalties.
Separately, Steven Medley had a tangle with the now defunct Danish stock exchange, GXG Markets, who suspected price manipulation by Medley’s GXG broker and former NZ financial service provider Quro Trust. (Quro still has a website here).
Here’s what Oppco’s website looks like.
The email below, covering an exchange between Milnes and S.Medley on Ruznakk Savings LP, was provided by Greenwell.
Date: Wed, May 27, 2015 at 10:08 AM
From: S. Medley
Date: Tue, May 26, 2015 at 2:03 PM
Subject: Re: Attn: The Compliance Officer: Ruznakk Savings LP – AML/CFT Act 2009
To: Robert Milnes <Robert.Milnes@dia.govt.nz>
Here are the answers to your questions.
2) We provide assistance to companies who want to list on many of the worldwide exchanges. We provide assistance with filings, connections, and managing of stock for shareholders after a company is listed. We also provide generic financial advice regarding the listing process. We provide assistance with the raising of capital for companies.
3) Ruznakk does not currently have any New Zealand based customers. Ruznakk does intend to have New Zealand clients, however we can not estimate how many as we have historically worked on listings on the stock exchange in New Zealand and have not been successful so far. Our lead in time to providing these FSP services to New Zealanders however, is very long as first we would have to get a company listed on the stock exchange and this period of time would allow us to get any AML compliance in place before delivering such FSP services.
5) No, however, we are currently looking to set up accounts in South Africa as we are anticipating a joint venture with a client there.
6) Our New Zealand representative, Adam Greenwell, attempts to get clients for our services to list companies on New Zealand or other country exchanges which if successful would also usually involve managing investment portfolios of stock and money for the company’s shareholders and he also attempts to help government and others to fund projects.
7) We do not have any offices outside of NZ. We have mailing addresses but that is all. We do not have any “employees” but I and 2 other representatives work opportunities outside of New Zealand. – UK, Germany, South Africa.
8) We do not have a website at this time but we are in the process of putting one together for our anticipated project in South Africa.
The bizarre response of Ron Powers
Greenwell says he has never spoken to Paul McDonald, the Christchurch director of NZ OSL Services Ltd, but was aware he was resigning his directorship.
And he has never heard of Ron Powers, whose name appears at the bottom of press releases about Oppco Savings & Loans, and who on LinkedIn is listed as the vice president of Worldwide Investment Consultants, whose president is Julie Roberts and who used Kea to connect with Greenwell. Several press releases are available from PR.Com with Powers’ name on the bottom. Here is one.
Denise emailed Ron Powers via the email address provided on PR.Com. She asked if he could put her in touch with someone to talk about Oppco Savings & Loans and NZ OSL Services as some “alarm bells” were sounding. She queried why it said on the Oppco website that there was no need to register as a financial service provider if you use NZ for offshore business and why the company was involved with the World Entertainment Charitable Trust as it seemed an odd mix. Below is Powers’ response on May 27 sent from his gmail address.
I don’t know who you are but most probably you are not a real journalist rather some sort of “Nigerian” scammer or fraudster as your email is full of, as you put it, “alarm bells”:
1) I no longer work at Oppco but I Ron Powers never put out this press release and whomever used my name mistakenly dated it a year ago (or put it out a year ago) and did not know my actual work email.
2) It is a pretty stupid press release. It gives out no information other than what what was already on the government FSP and corporate websites for years. Why would anyone bother to put out such mundane information, other than YOU are the source and are using it to perpetuate some scam?
3) The statement on the website you refer to was approved by the NZ FMA after several months of scrutiny by them. That is their position. If you were a real journalist you would have done your homework already and would know both the law and our srutinisation history and wouldn’t make such a blatantly incorrect statement.
4) “Gmail” address? Right, you’re a real “journalist”.
5) You picked the wrong website to supposedly be writing for as “interest.co.nz” specifically came up by name in our discussions with the FMA – obviously if you were a real “freelance” journalist you would have picked another more reputable website to be supposedly writing for – another mistake made by an [sic] probable scammer. Despite inaccurate and libelous articles published by that site, our registrations were fully reviewed by the NZ FMA and we were NOT deregistered. Again, if you were truly the investigative journalist you claim to be, you would have known that as it is a simple matter of public record.
I don’t know what “scam” you are up to here, but I am blocking your email and forwarding a copy of your email to abuse department at PR.com.
Maybe they can track down who you really are if you are the one who published the fraudulent Press Release.
I am also going to forward this email to a real journalist I know who writes about “Nigerian scams”, “unprofessional journalists” and other scams. As I understand it the laws in Nigeria protect people like you from prosecution, but maybe a little “exposure” will keep people like you from running your scam on others.
And if there is an outside chance that you are a real journalist, which I doubt, go ahead and publish the stupidity you assert in your email as even though I do not work for Oppco any more, I will make sure your inaccuracies and unprofessionalism come to light and you will be held out to public “mockery” and “ridicule” by your own foolish words.
Have a good day, Denise McNabb, if that is even your real name.
The FMA’s response & MBIE’s review
The FMA, or Financial Markets Authority, referred to by Powers, has a somewhat different take on events. An FMA spokesman says the regulator has not approved any statement for Oppco or NZ OSL Services to run on its website. The spokesman says the FMA did engage with the firm because it felt it had no need to be on the Financial Service Providers Register (FSPR). This was because Oppco/NZ OSL Services offered no services within NZ, and had no large scale operations in the country.
“We considered their registration and as they showed us they have New Zealand clients, there was no need to remove them from the FSPR or take further action,” the FMA spokesman says.
But he adds registration as a NZ financial service provider is merely registration on a list. “It doesn’t mean you’re regulated or licensed,” the FMA spokesman says.
The NZ Government is currently reviewing the FSPR after acknowledging misuse of it. The Ministry of Business, Innovation & Employment (MBIE) says it will provide a report, featuring its recommendations, to Minister of Commerce and Consumer Affairs Paul Goldsmith by July 1.
In an issues paper MBIE says the following;
We are aware of instances of foreign-based financial service providers, particularly foreign exchange operators, registering on the Register – primarily to take advantage of New Zealand’s reputation as a well-regulated jurisdiction. The FSP [Financial Service Providers] Act only applies to persons ordinarily resident in New Zealand, those with a New Zealand place of business, or those who are required by other legislation to be licenced or registered under the Act. Some offshore providers have gone to some lengths to set up shell New Zealand operations.
While this may not have an impact on New Zealand businesses or consumers directly (as these providers typically avoid offering services to New Zealanders), it creates a risk to both New Zealand’s reputation as a well-regulated jurisdiction and to the reputation of legitimate New Zealand financial service providers. It also causes issues for dispute resolution schemes who receive complaints from overseas consumers.
The World Entertainment Charitable Trust
Greenwell, meanwhile, seemed only vaguely aware of the World Entertainment Charitable Trust, which says on its website that NZ OSL Services Ltd is its funder.
The Trust is described as an entirely privately funded Non-Government Organisation, a NZ Foreign Trust, that “assists charities, churches and non-profits around the world to raise money for charitable, environmental and humanitarian causes, through live and online entertainment events.”
*World Entertainment Charitable Trust is funded 100% by NZ OSL Services Ltd. A Registered New Zealand Financial Service Provider. (FSP16601).”
Below is what the website looks like.
Powers says he is not the author of any of the press releases, but here is another one from last year under the name of Oppco Savings & Loans featuring his contact details.
Oppco Savings and Loans Lmited Signs LOI with Interdream Holdings
Wellington, New Zealand, April 07, 2015 — (PR.com)– Oppco Savings & Loans Limited, a New Zealand registered Financial Service Provider is pleased to announce that it signed a letter of intent to provide a $25 million USD financial guarantee to InterDream Holdings, a Japanese company, for expansion of their international business.
Oppco Savings & Loans specializes in a variety of services for wealth management. We help both wealthy individuals and companies worldwide to mange their funds and to “internationalize” to protect wealth, maximize opportunity and expand cash flow and asset base. Oppco Savings & Loans also helps companies achieve public listings of their stock on the Global Stock Exchanges in order to assist its clients in creating corporate wealth and wealth for the corporation’s shareholders. http://www.oppcosavingsandloans.co.nz
InterDream is a global real estate investment management firm. We are an active participant in the three core segments of the global real estate property and capital markets. With on-the-ground private and public market investment teams in North America, Europe, and Asia-Pacific, we execute core, value-added, and opportunistic strategies for investors seeking investments in:
Private Real Estate Equity: Direct investments in property Real Estate Securities: Investments in publicly traded, listed securities, including REITs, REOCs and other real estate companies traded regionally and globally Real Estate Debt: Direct investments in property secured by senior and mezzanine mortgage positions Within each discipline, our portfolio compositions reflect investment expertise developed over multiple economic and market cycles across the risk/return spectrum.
For more information, please contact us at : firstname.lastname@example.org
This Press Release may contain certain forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Oppco has tried, whenever possible, to identify these forward-looking statements using words such as “anticipates”, “believes”, “estimates”, “expects”, “plans”, “intends”, “potential” and similar expressions.
These statements reflect Oppco’s current beliefs and are based upon information currently available to it.
Oppco Savings & Loans, Limited
Ron Powers +44 8447047689+44 8447047689 x440
If Greenwell knew about the US$25 million loan to InterDream from Oppco he wasn’t saying. Responding by email, Keiko Ishihara, a spokeswoman for InterDream Holdings, says the firm did sign an “LOI” with Oppco for a US$25 million financial guarantee. However she says InterDream “never followed through on the intend.”
“InterDream Holdings has not have any contact since the middle of 2015 and had no further engagements with Oppco,” Ishihara says.
But here is the final word from Greenwell, who is still holding out hope for his sukuk bonds:
“To my knowledge, even the British Prime Minister has not divulged the source of sukuk financing for the current rebuild of the Palace of Westminster. That is not to say that his government’s funding sources are not legitimate.
There are two key words coming out of my experience in this domain since 2013: Investment and Compliance. I have in the main, been dealing with a large investment offer that requires a workable relationship with the government of the day. I have reported, and fulfilled – (with a lot of unpaid effort) – my obligations of compliance with the relevant government departments.
As well as working hard to gain traction in these areas, I have had to cope with a life- threatening health challenge to my mother (politically-instigated); the passing of my father; and the flooding of my home, all in recent succession.
I applaud and stand shoulder-to-shoulder with any efforts to present New Zealand as a transparent and beneficial place to do business, generate jobs and wealth, and be ideally free of corruption.”
Update 02/08/2016: This story has been updated to correct the name of Adam and Elizabeth Greenwell’s company to Town Green Music Ltd from Town and Music Ltd. We’ve also added additional detail clarifying Stan Medley’s run-in with the SEC, which played out over several years.